Transcript Document

Validation, Verification, Qualification:
Which is right and does it really matter?
Definitions:
(According to Webster, relative to quality endeavors)
Validation is an act, process, or instance to
support or corroborate something on a
sound authoritative basis
•Verification is the act or process of
establishing the truth or reality of something
•Qualification is an act or process to assure
something complies with some condition,
standard, or specific requirements
•
Definitions:
(According to the FDA)
Per the Code of Federal Regulations Title 21 – Food and
Drugs, Part 820 – Quality System Regulations:
•Validation means confirmation by examination and
provision of objective evidence that the particular
requirements for a specific intended use can be
consistently fulfilled. [CFR 21 Part 820.3(z)]
•Verification means confirmation by examination and
provision of objective evidence that specified requirements
have been fulfilled. [CFR 21 Part 820.3(aa)]
•Qualification – NOT DEFINED
BSC Examples
Validation Examples:
•Design Validation, Sterilization Validation, Test Method Validation,
Software Validation, and Process Validation
Verification Examples:
•Design Verification and Process Verification.
Qualification Examples:
•Installation Qualification, Operational Qualification, Process
Performance Qualification, Product Performance Qualification, and
Supplied Material Qualification
Some General Observations
(When the Terms are Used)
•Verifications tend to be used when assessing something
completed that is static and is not prone to inadvertent
change.
•Validations tend to be used when assessing something
dynamic that is more prone to inadvertent change. They
also tend to be larger endeavors including one or more
subordinate qualifications (and/or verifications).
•Qualifications tend to be smaller in scope than
validations, tend to be less dynamic, and are frequently a
subset of a greater validation initiative.
General Observations
(BSC Examples)
•A Design Verification verifies that a frozen (static) design
meets top level product specifications.
• A Process Validation validates that the on-going
(dynamic) manufacturing process produces product that
meets product/print specifications and consist of
Installation Qualifications, Operational Qualifications,
Process Performance Qualifications, a Product
Performance Qualification and perhaps Process
Verifications.
•An Installation Qualification qualifies that equipment was
installed correctly and are a subset of a Process
Validation (or possibly a Test Method Validation).
Validation, Verification, and Qualification
So how important is the name of these activities (Val, Ver, Qual)?
Not that important at all.
So what does matter in all of this?
What matters most is the nature and timing or the activity, not the
name of the activity.
Nature: Who, what, (possibly where), why, and how is the activity being
objectively demonstrated.
Timing: When can the activity be started and when must the activity be
completed.
Validation, Verification, and Qualification
TEST METHOD VALIDATION
Test Equipment
Installation
Qualification
Test Equipment
Operational
Qualification
Design Verification
Gage R&R or
conformance to
standard (MQ)
Design Validation
PROCESS VALIDATION
Manufacturing
Equipment
Installation
Qualification
Manufacturing
Equipment
Operational
Qualification
Process
Operational
Qualification
Process
Verification
Process
Performance
Qualification
Product
Performance
Qualification
Validation, Verification, and Qualification
(Generic Verification/Validation/Qualification Considerations)
•Assessment conducted per pre-established plan and/or
protocol(s) with clear vision of what constitutes “success.”
•Objective Acceptance Criteria (generally statistically based).
•Ideally, acceptance criteria determination should be risk
based.
•Assessment should be thoroughly documented, yet concise.
•Final report should justify all deviations and have clear
concise conclusion (i.e. Pass or Fail).
Validation, Verification, and Qualification
(Test Method Validation Considerations)
PURPOSE:
• Demonstrate that the test method is appropriate
for the specification being assessed.
• Provide objective evidence of consistent operation
of test equipment and results.
• Demonstrate that the test method discriminates
borderline acceptable from unacceptable product
or part.
Note: Could entail meeting a standard or conducting
analysis such as Gage R&R
Validation, Verification, and Qualification
(Test Method Validation Considerations)
TIMING: Before Using in a formal study
RECORDS: TMV Protocol and Report
• Potentially: Equipment prints and specs, software
validation documentation, data sheet validation
documentation.
PERSONAL INSIGHT:
Make sure your acceptance criteria is realistic.
Validation, Verification, and Qualification
(Design Verification Considerations)
PURPOSE:
• To establish documented evidence that the design
output meets pre-established design input
requirements as identified in the Product
Specification.
TIMING:
• During development phase on a frozen design,
generally prior to Process Validation
Validation, Verification, and Qualification
(Design Verification Considerations)
RECORDS: DV Master Plan (DVMP), DV Protocols,
DV Report(s) [Perhaps a DVMR]
PERSONAL INSIGHT:
•Remember it’s a verification, not a discovery
experiment. Success should be at least probable.
•Limit/Challenge testing (if not done earlier) is critical
to defend spec tolerances.
•Should use risk based, statistical acceptance criteria
•Use contingency planning in DVMP and DV
Protocols (e.g. double sample attribute plans vs.
single sample attribute plans) anticipate issues (vs.
writing deviations in the report)
Validation, Verification, and Qualification
(Design Validation Considerations)
PURPOSE:
• To ensure that device designs conform to defined
user needs and intended uses as identified in the
Market Specification.
TIMING:
• Planning should start as soon there is a Market
Specification. The Design Validation must be
completed before full product launch.
Validation, Verification, and Qualification
(Design Validation Considerations)
RECORDS: DVal Plan, DVal Protocols, DVal Report(s)
PERSONAL INSIGHT:
•The earlier, the better.
•Leverage DV results where appropriate (should be defendable).
•Be realistic in acceptance criteria (some requirements are very
hard and/or very expensive to validate).
•Consider used risk based criteria.
•Avoid redundant assessments of the same requirement.
•Avoid over reliance on pre-release market evaluation product
surveys.
Validation, Verification, and Qualification
(Process Validation Considerations)
PURPOSE:
• To establish documented evidence that a process
consistently produces an output that meets its
predetermined requirements and that the overall
manufacturing line produces a product that meets
finished device requirements.
TIMING:
• Planning can start as design and process are
solidified. The Process Validation must be
completed before full product launch.
Validation, Verification, and Qualification
(Process Validation Considerations)
RECORDS: Master Validation Plan (MVP), PV Protocols, Master
Validation Report (MVR)
PERSONAL INSIGHT:
•Limit/Challenge OQ testing at parameter limits is critical to
defending full process.
•Decide early what constitutes validated window for future
process changes.
•Should use risk based, statistical acceptance criteria.
•As with DV, use contingency planning in MVP and PV Protocols
(e.g. double sample attribute plans vs. single sample attribute
plans) anticipate issues (vs. writing deviations in the report).
•Plan for line extensions and other likely future changes when
planning and identify the requirements for implementing those
future changes.
Validation, Verification, and Qualification
Questions, Discussion